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KEY REQUIREMENTS AND DATES
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Control devices must reduce methane and VOC by 95% or more
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ECDs not on EPA's manufacturer-tested list need an initial performance test
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TOC performance testing under 60.5413b(b): due January 22, 2027
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Pilot flame and alarm requirements: January 22, 2027
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Visible emissions observations: not extended, still in effect
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NHV sampling narrowed by the April 2026 rule; a 14-day demonstration is allowed where it applies
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A Phase 2 reconsideration is pending; we'll post updates on our blog
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